Yesterday, on November 1, 2010, the proposed changes in the US Sentencing Guidelines became effective. This post will highlight the changes and what they may import for the FCPA compliance professional. The US Sentencing Guidelines are used in the sentencing of organizations and serve as the de facto blueprint for corporate ethics and compliance programs. The changes, which were approved at an April meeting of the US Sentencing Commission and were formally submitted to Congress by May 1, became effective yesterday. These proposed changes followed public hearings and public comment period which ended in March. The most significant changes in the Sentencing Guidelines are as follows.
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